Database of Precedents

Application	Initial
Review	Full, coordinated by ENQA
Decision of	11/10/2024
Standard	2.4 Peer-review experts
Keywords	students
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“26. The Register Committee learned from the analysis of the panel that at the time of the review, some provider and programme accreditation procedures did not involve experts and that these procedures were conducted by MFHEA’s staff. The Committee understood that the only reviews that involved panels were the accreditation procedures for provider seeking university status and EQA Audit (see also ESG 2.3).

27. In its statement to the report, MFHEA informed that the revised manuals, referenced earlier in this decision, require that now every procedure is conducted by an external review panel of a minimum of three experts out of whom one is a student.

28. The Register Committee took note of the actions taken by the agency. Nevertheless, the Committee could not confirm whether these changes have been implemented in practice.

29. In its additional representation, MFHEA referred to the new manuals for provider and programme accreditation where the involvement of students in every external review panel will be guaranteed. Furthermore, MFHEA informed that despite that, the new Programme Accreditation Manual would be in place as of January 2025, the agency already includes students in the review panels for programme accreditation procedures.

30. From the additional representation, the Committee has learned that at the given time only a very small portion of programme accreditation reports are available on MFHEA’s website and further publication of reports is planned in January 2025 (see ESG 2.6). From the limited number of reports available online, the Committee could see that the agency started including a student reviewer in the expert panel.

31. The Register Committee welcomed the changes made by the agency in order to involve students in all external review procedures and encouraged MFHEA to continue this practice. The Committee, however, found that it remains to be evaluated by an external panel whether the planned changes have been consistently implemented and students are included in all programme review panels once the new programme accreditation manual is adopted. Therefore, the Committee concurred with the panel that the agency complies only partially with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	11/10/2024
Standard	2.5 Criteria for outcomes
Keywords	inconsistency in outcomes
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“32. MFHEA has established a National Quality Assurance Framework (NQAF), which sets the parameters for external quality assurance in Malta. The Register Committee learned that at the time of the review, only the standards for the EQA Audit procedures mirrored the NQAF standards and that only for that procedure the criteria were clearly defined and ensure a consistent judgement of each standard.

33. The panel noted several inconsistencies regarding the rest of the MFHEA’s activities. For example, the NQAF standards for programme accreditation were not clearly referred to in the internal application form. Similar challenges were noted in the report for awarding university status to a provider; the report did not follow the application form where the NQAF standards were referred to.

34. Furthermore, the panel could not find further evidence that the agency had a clear approach which standards and procedure manuals are applied in its activities. The panel could not find consistency in the agency’s guidelines, standards and manuals. The panel was also unable to find guiding criteria for outcomes in order to ensure a consistent judgement for all types of providers and programme accreditation.

35. In its statement to the report, MFHEA informed that it addressed some of the panel’s recommendations in its revision of the Accreditation Manual for Higher Education Institutions; for the Committee, though, it was unclear what particular changes took place to address the shortcomings. The agency also explained that they will further address the shortcomings in the new

Programme Accreditation Manual in January 2025.

36. The Committee could follow the panel’s view and found that the agency did not have clear criteria for outcomes and that there is lack of consistency in their implementation for most of its procedures, as well as the lack of systemic approach to ensuring consistency in its decision making.

37. In its additional representation, MFHEA informed that the concerns raised by the Register Committee have been or will be addressed with the respective manuals for provider and programme accreditation procedures. Furthermore, MFHEA informed that at the given time, they are designing the guidelines for the Quality Assurance Committee and its peer reviewers to refine its criteria for outcomes.

38. The Register Committee noted the steps taken by MFHEA to formulate its criteria for outcomes for programme and provider accreditation procedures in a clear manner in its new manuals. The Register Committee, however, found it challenging to assess the practical implementation without a panel insight. The Committee also found that the new programme evaluation manual is yet to be adopted and implemented in practice. Following this, the Committee thus concurred with the panel’s conclusion that MFHEA complies partially with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	11/10/2024
Standard	2.6 Reporting
Keywords	publication of reports
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“39. The Register Committee learned from the analysis of the panel, that the agency did not publish all of its reports from its programme and provider

accreditation procedures.

40. In its statement on the report, the agency informed that with the publication of the new manuals, as of January 2024 and January 2025 respectively, all accreditation reports and decisions will be published on its website. The Register Committee, however, could not find any recently

published reports when performing an additional check on the MFHEA’s website.

41. In its additional representation, MFHEA informed that as of January 2024, all accreditation decisions are to be published on the MFHEA website

together with the expert panel reports. MFHEA further explained that “the reason no Provider Accreditation Reports have been found on MFHEA

website is that since this is a recent development, to date no provider accreditation have been finalised and therefore there were no provider

accreditation reports to publish” and that “with regards to programme accreditations there is a small number of reports which are ready. It is expected that actual publication will happen in January 2025…”.

42. The Register Committee took note and welcomed the planned actions by MFHEA to ensure that all reports and decisions are publicly available. The Committee found that, however, the presented actions are yet to be implemented in practice and once implemented, remain to be reviewed by

an external review panel.

43. Therefore, the Committee concurred with the panel that the agency complies only partially with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	11/10/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	student in governance, distintion between activities
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“44. MFHEA has a mission statement which is publicly available and included in the strategic plan. As outlined by the panel, however, the strategic plan lacks a detailed outline of clear and explicit goals.

45. The Committee learned from the panel’s analysis that MFHEA did not ensure a clear distinction between its external quality assurance activities in the field of higher education and its other fields of work. In its statement on the report, the agency explained in order to enable a clear distinction

between its activities, it plans to initiate legislative changes. These changes, however, were either planned to happen later in 2024 or in 2025.

46. The Register Committee also learned from the report that MFHEA involves external stakeholders from different sectors in its governance and

work, e.g., members of the Board have different backgrounds in higher education. The Committee, however, noted that students are not involved in

the work of the governance body (or governance), i.e., the Board nor in its accreditation body, i.e., the Quality Assurance Committee (QAC). The Register Committee understood that in order to ensure better involvement of stakeholders, including students, in its governance structures, MFHEA

has foreseen legislative changes.

47. For the Committee it was unclear which particular changes will take place in order to address the lack of clear distinction between higher education and non-higher education activities and the lack of student involvement in the governance and work of the agency (in the Board and the

QAC), and whether the planned legislative changes have been adopted yet

48. In its additional representation, the agency informed that the clear distinction between MFHEA’s external quality assurance activities in higher

education and its other fields of work, will be ensured through structural changes in its organisational structure; the agency plans to set two units

tackling further and higher education separately.as of January

2025. Furthermore, the agency informed that legal provisions were amended to

include student representatives in the Quality Assurance Committee and the MFHEA Board and that students are now represented in both of them.

49. The Register Committee noted and welcomed the planned changes aiming to ensure clear distinction between its external quality assurance

activities in the field of higher education and its other fields of work and the involvement of students in the Board and the Quality Assurance Committee.

50. However, given the concerns raised above and that relevant parts of the presented actions are yet to be fully translated into the daily work of the

agency, they remain to be reviewed by an external review panel. Therefore, the Committee could not concur with the panel and found that the agency complies only partially with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	11/10/2024
Standard	3.3 Independence
Keywords	government involvement, organisational independence
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Partial compliance

“51. The Register Committee learned from the report that the members of the MFHEA Board are all nominated by the Minister responsible for

education and appointed by the Prime Minister of Malta. The Prime Minister also nominates the Chairperson and Deputy Chairperson of the Board, who undergo parliamentary scrutiny before being officially appointed. Furthermore, the dismissal and resignation of the Board members could be

only done by or via the Prime Minister.

52. Following the panel’s analysis, the Register Committee expressed its concerns that the organisational independence of the agency is constrained by its strong link and dependency on the government. This is reinforced by the small size of the higher education system.

53. The Quality Assurance Committee (QAC) of MFHEA is the body responsible for decision making on external quality assurance of further and

higher educational institutions. The MFHEA Board, on the other hand, is responsible for endorsement of the evaluation decisions taken by the QAC.

The panel noted inconsistencies regarding what accreditation procedures and which decisions are being endorsed by the Board. Further, as noted by the panel, the participation of the head of QAC, a body appointed by the Board, in the endorsement of QAC’s decisions as a Board member could create internal conflict of interest.

54. In its additional representation, the agency stated that “There are several layers to ensure the independence and suitability of the members of

the Board. These are nominated by the Minister for Education, however they are appointed by the Prime Minister and the Chairperson needs to be

approved by the Public Appointments Committee which is a Parliamentary committee made up of members from both sides of the House (Parliament) which conducts Parliamentary Scrutiny of the nominee. The law also lists the eligibility criteria for Board members, thus ensuring the objective suitability of person nominated by the Minister and appointed by the Prime Minister.”

55. Furthermore, the agency clarified that the current chairperson of the newly appointed QAC has not been appointed as a member of the Board and that the process for the required legislative changes to reflect this distinction are currently underway.

56. The Register Committee considered the additional representation and welcomed the distinction between the two bodies by excluding the

chairperson of the QAC in the Board. The Committee found that, however, this practice is yet to be codified as to ensure continuous prevention of

conflict of interest within the accreditation process. Furthermore, the committee maintains its concerns raised by the panel on the inconsistencies

regarding what accreditation procedures and which decisions are being endorsed by the Board.

57. Finally, the Committee maintains its concerns raised above about how the organisational independence of the agency is constrained by its strong link and dependency on the government.

58. Therefore, the Committee could not concur with the panel and found that the agency complies only partially with the standard.”

Full decision: see agency register entry

Application	Initial
Review	Full, coordinated by ENQA
Decision of	11/10/2024
Standard	3.4 Thematic analysis
Keywords	thematic analysis
Panel conclusion	Compliance
Clarification request(s)	Agency (24/09/2024)
RC decision	Compliance

“59. The Register Committee learned from the report that the agency has conducted only one thematic analysis, focussing on only one standard from

its EQA Audit procedures carried out by the agency as of

2016.

60. The Committee learned that the agency is considering conducting a thematic analysis for the remaining ten standards. The panel, however, was

not provided with further information on the status of the development of this analysis or, in general, MFHEA’s policy on thematic analysis.

61. The Register Committee noted the agency's plans to revisit its policy and enhance its work on the thematic analysis. The Register Committee

found that these plans have yet to materialise in practice.

62. In its additional representation, the agency informed that it was in a process of conducting its latest thematic analysis and the same should be

finalised by the end of

2024.

63. The Register Committee further asked for clarification whether the work on the thematic analysis is ongoing and whether there is a clear

timeframe when the thematic analysis will be published. The agency clarified that the thematic analysis is currently being finalised and will be

published and presented to the public in December 2024 (see minuted clarification of 2024-09-24).

64. The Committee welcomed the work and progress done by the agency in producing thematic analysis and expects that MFHEA will continue

conducting thematic analysis on regular basis. Given the provided information in the additional representation and the further clarification,

the Register Committee could concur with the panel that the agency is in fact compliant with ESG 3.4.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	04/04/2024
Standard	2.7 Complaints and appeals
Keywords	appeals procedure, appeals committee
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“7. In the decision on the for inclusion of CYQAA on the register (of 2019-11- 05), the Register Committee raised concerns regarding the shortcomings of the appeal procedure regarding the independence of the processes and the lack of clearly defined and formal complaints procedure.

8. From the external review report, the Register Committee learned that the Complains Policy is well established and higher education institutions have already used the possibility to submit a complaint (18 until the time of the external review).

9. The Register Committee further learned that CYQAA has revised its Appeals Procedure and now sets Advisory Committee of Experts (ACE) - groups of experts that examine and give opinion on the grounds for appeals to CYQAA’s Council. Despite the updated policy, the Council still holds the powers to make the final decision whether there are grounds for an appeal and can dismiss or uphold the appeal.

10. Furthermore, the Committee noted that the current Appeal Procedure is not entirely clear as it may suggest that an ACE is appointed for each appeal that is allowed for consideration by the Council, whereas in practice it is set only when the Council proposes to reject an appeal and needs advice from external experts.

11. The Register Committee welcomed (changes made related to the complaints procedure) and found the earlier concerns related to the complaints procedure addressed. The Committee, however, found that CYQAA is yet to demonstrate an independent functioning of the Appeals Procedure, where the final decision is not with CYQAA’s Council. Having in mind the shortcomings related to the Appeals Procedure, the Register Committee concurred with the panel conclusion that CYQAA only partially complies with ESG 2.7.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	04/04/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	strategic plan, stakeholder, stakeholders involvement
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“12. The Register Committee noted the concerns raised by the panel that CYQAA’s Strategic Plan (2020-2025) is rather generic, with no specific

activities and clear timeframes. Furthermore, the Committee noted that the panel did not see any evidence of public, annual corporate or activity plan than operationalise the Strategic Plan.

13. The Register Committee understood by the panels analysis, that the agency involves representatives from both public and private universities, students and regulated professions. However, as underlined by the panel, the involvement of private higher education institutions and many public and private colleges and their students is very limited and CYQAA should further widen their engagement in its governance and evaluation processes.

14. Considering the lack of comprehensive and rather generic Strategic Plan and the shortcomings in the involvement of stakeholders from all

higher education institutions, public and private colleges, the Register Committee concurred with the panel and found that CYQAA only partially

complies with ESG 3.1.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	04/04/2024
Standard	3.3 Independence
Keywords	operational independence, methodologies
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“15. In the decision for inclusion of CYQAA on EQAR (of 2019-11-05), the Committee raised concerns regarding the shortcomings related to the operational independence of CYQAA and the close interlinkage between the agency and the responsible ministry.

16. Despite some progress being made by consultation with key stakeholders on the appointment of Council members and the Minister, the Register Committee noted that the Council members are still appointed by the Council of Ministers, upon recommendation by the Minister responsible for higher education.

17. The Register Committee took note of the panel’s concerns regarding the operational independence of the agency, The Committee understood that CYQAA cannot hire its own staff and is fully relying on secondments from the central Government and the Ministry of Education, Sport and Youth.

18. The Register Committee further noted, as underlined by the panel, that despite being fully independent in defining its evaluation methodologies, CYQAA is still challenged by the limits set in the provisions of the national legislation regarding engaging stakeholders in the development of methodologies (see issue raised under ESG 2.2 in the external review report).

19. Following the panel’s analysis, the Register Committee expressed its concerns that the operational independence of CYQAA remains constrained by the close link and dependence on the Ministry of Education, Sport and Youth regarding the appointment of the Council members, hiring of staff and engaging stakeholders in the development of methodologies. Therefore, the Register Committee concurred with the panel conclusion, and found that CYQAA remains to be partially compliant with ESG 3.3.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	2.5 Criteria for outcomes
Keywords	Inconsistent use of tools for decision making; Consistency in the interpretation of the agency’s criteria
Panel conclusion	Partial compliance
Clarification request(s)	Panel (28/05/2024)
RC decision	Partial compliance

“The Register Committee learned that, out of 24 applications concluded between

2022 and 2024, the final conclusions on the standards differed from those

proposed by the panels in four cases – three of which occurred in

2024. This

trend resulted in either more or less favourable outcomes for the concerned

higher education institutions.The Committee could not understand, without a panel insight, whether

the increased discrepancy between the panels’ and the Authorisation

Council’s conclusions occurring after the site visit (2023-11-05) steams from

the (im)proper use of the tools for consistent application of agency’s criteria

or other external factors (see more in ESG 3.3)”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	27/11/2024
Standard	3.3 Independence
Keywords	High level of involvement of the Government of Georgia in the selection of candidates for several leadership and managerial positions in the agency
Panel conclusion	Partial compliance
Clarification request(s)	Panel (28/05/2024)
RC decision	Non-compliance

“The Register Committee found that the agency remains having weak

organisational independence as the government persists having strong involvement in the appointment of several NCEQE’s bodies. The Committee found that further panel insight should asses whether the Government’s significant involvement in the agency’s operations affects the notable staff overturn (i.e. the operational independence) and the final conclusions of the accreditation decisions (i.e. the independence of formal outcomes).”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.1 Consideration of internal quality assurance
Keywords	Internal quality assurance
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“8. In its last decision for renewal of registration on EQAR (of 2020-03-16), the Register Committee found that AHPGS only partially fulfilled the requirements of the standard, as the ESG Part 1 was not properly addressed in their external reviews outside Germany.

9. The Committee understood that in order to address these issues, AHPGS revised its handbooks for reviews abroad. Nevertheless, the Committee understood by the analysis of the panel, that the Handbook for Institutional Evaluations does not address standards 1.7, 1.8 and 1.9 sufficiently.

10. Furthermore, the Committee understood from the analysis of the panel, that programme accreditation reports were in line with ESG Part 1, except one which did not follow AHPGS’s own criteria in full.

11. In a statement of the report (of 2024-05-17), AHPGS explained that in order to address the shortcomings underlined by the panel, it revised its handbooks for programme and institutional accreditation outside Germany.

12. The Committee welcomed the changes made by AHPGS. The Committee was, however, unable to conclude whether the adopted changes are implemented in practice without further panel insight and therefore they remain to be reviewed within the next external review of the agency. The Register Committee, therefore, concurred with the panel’s conclusion and found that the agency remains partially compliant with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.4 Peer-review experts
Keywords	Training of experts
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“13. In its previous decision of registration on EQAR (of 2020-03-16), the Register Committee found AHPGS to be partially compliant with the standard due to ambiguity in whether the agency ensured that all experts received training. Additionally, the criteria and process for recruiting reviewers were not clear.

14. From the report, the Register Committee learned that the training process has been improved, and ensures inclusivity and accessibility for all experts. Furthermore, as underlined by the panel, the format was made more adaptable and personalised.

15. Following the improvements made by the agency, the Committee was able to follow the panel’s conclusion that the agency now complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	3.4 Thematic analysis
Keywords	Thematic analysis
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“16. In its previous decision of registration on EQAR (of 2020-03-16), the Register Committee found the agency to be partially compliant with the standard, as the publications prepared by the agency did not analyse the outcomes of the review processes.

17. Based on the analysis of the review panel, the Register Committee understood that, since its last review in 2020, the agency published several thematic analyses. Conducting additional studies is also now part of the agency’s strategic documents.

18. The Register Committee was able to follow panel’s conclusion that AHPGS is now compliant with the standard. The Committee, further highlighted the panel’s recommendation that the agency should secure adequate dissemination of its thematic analysis, keeping in mind the various target audiences.

19. For the remaining standards, the Register Committee was able to concur with the review panel's analysis and conclusion without further comments.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	2.6 Reporting
Keywords	Publication of reports
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“8. From the report, the Register Committee learned that in case of the activities leading to an accreditation of German higher education institutions, there is a (theoretical) possibility that an institution may not forward the report to the German Accreditation Council (GAC); hence the report may not be published.

9. The Register Committee concurred with panel’s conclusion and found the agency compliant with the standard. It, however, underlined panel’s recommendation that the agency could include a publishing clause in the contract with the higher education institution in case the report to the German Accreditation Council is not forwarded.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	02/07/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Clarity in activities and services; Conflicts of interest
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“10. While the Register Committee was able to follow panel’s conclusion that AQ Austria is compliant with the standard, it highlighted the panel’s recommendation that the agency should enhance the clarity on its ESG aligned activities and consultancy services for the public and add explanation on avoiding conflicts of interest on their website.

11. For the remaining standards, the Register Committee was able to concur with the review panel's analysis and conclusion without further comments.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	2.6 Reporting
Keywords	Publication of reports with negative outcomes, publication of expert panel reports
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“8. In its previous decision for renewal of registration on EQAR (of 11-05- 2019), Unibasq was found to be partially compliant with the standard as it did not publish reports of its ex-ante accreditation resulting with a negative outcome. From the report, the Register Committee learned that the agency now publishes these reports too.

9. The Register Committee further learned that the preliminary and final review reports shared with the higher education institutions and the public do not include the expert panel reports; these reports are only available to the Unibasq’s Committees.

10. The Register Committee found that the agency addressed the concerns raised in its earlier decision regarding the publication of negative reports from its ex ante accreditation procedure. It, however, shared the panel’s concerns that the agency does not fully comply with this standard because of the lack of transparency regarding the expert panel reports.

11. The Register Committee therefore concurred with the panel’s conclusion and found that the agency remains partially compliant with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	2.7 Complaints and appeals
Keywords	procedure for handling complaints
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“12. In its previous decision for renewal of registration on EQAR (of 11-05-2019), Unibasq was found to be partially compliant with the standard due to the unclear procedure for handling complaints. From the report, the Committee learned that Unibasq now has a well established complaints procedure noted in the agency’s regulations of the Ethics and Guarantees Committee and the Code of Ethics.

13. Following the changes made by the agency, the Committee was able to follow the panel’s conclusion that the agency complies with the standard.”

Full decision: see agency register entry

Application	Renewal
Review	Targeted, coordinated by ENQA
Decision of	04/04/2024
Standard	3.1 Activities, policy and processes for quality assurance
Keywords	Distinction between ESG aligned and consultancy activities
Panel conclusion	Compliance
Clarification request(s)	–
RC decision	Compliance

“14. In its previous decision for renewal of registration on EQAR (of 11-05-2019), Unibasq was found to be partially compliant with the standard as it did not make a clear distinction between its ESG aligned and consultancy activities (i.e. the evaluation of “títulos propios”). At the time, the agency removed the information regarding the evaluation of “titulos proprios” from its website; the Committee, however, could not verify whether the new method of communication brought clarity for all stakeholders.

15. From the external review report, the Committee has learned that the agency “ has made...efforts to request from higher education institutions [involved in the consultancy activities] not to use misleading information on their websites and has succeeded as far as the panel could determine through an internet search”.

16. The Committee therefore followed the panel’s conclusion and found that the agency now complies with the standard. The Committee, however, shared the panel’s view that the agency could improve the distinction between these two group of activities by creating a separate section on its website where it showcases clear information to the public.

17. For the remaining standards, the Register Committee was able to concur with the review panel's analysis and conclusion without further comments.”

Full decision: see agency register entry

Application	Renewal
Review	Full, coordinated by ENQA
Decision of	12/12/2023
Standard	3.3 Independence
Keywords	operational independence, decision-making
Panel conclusion	Partial compliance
Clarification request(s)	–
RC decision	Partial compliance

“8. In its last decision, the Register Committee noted the strong role the German Bishops’ Conference (DBK) plays in the governance of the agency.

9. Despite the changes made by the agency to further its operational independence, the Register Committee noted that DBK maintains a significant role in the organisational structure of AKAST.

10. The Committee underlined the possible influence that may be exerted by the DBK Episcopal Commissioner in the decision making of the Accreditation Committee. Although the Episcopal Commissioner is present in the Accreditation Committee (AC) of the agency in an advisory capacity, there is still the possibility of undue influence considering the fact that the Episcopal Commissioner still issues a separate consent impacting the programme.

11. Furthermore as noted by the panel, it also seems possible for the episcopal commissioner to express, even unintentionally, a preliminary opinion on particular study programmes, not necessarily based on the findings of the expert panel during the AC meeting.

12. The Committee noted the concentration of power in one place, i.e., the current Chairperson of the Executive Board of AKAST holds the position of Chair of the Accreditation Committee and Chair of the Advisory Board of AKAST. Furthermore, the DBK nominates the Chairperson of the Executive Board.

13. Considering the strong influence of one main stakeholder in the running of the agency, the Register Committee underlined the risk to the agency’s operational independence, as well as to its independent decision-making. The Register Committee therefore concurred with the panel’s view that AKAST complies only partially with ESG 3.3.”

Full decision: see agency register entry